Laboratory Corp. of America v. Hunter Smith

CourtKentucky Supreme Court
DecidedAugust 22, 2024
Docket2023-SC-0479
StatusPublished

This text of Laboratory Corp. of America v. Hunter Smith (Laboratory Corp. of America v. Hunter Smith) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Laboratory Corp. of America v. Hunter Smith, (Ky. 2024).

Opinion

RENDERED: AUGUST 22, 2024 TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0479-WC

LABORATORY CORP OF AMERICA APPELLANT

ON APPEAL FROM COURT OF APPEALS V. NO. 2023-CA-0604 WORKERS’ COMPENSATION NO. WC-21-95319

HUNTER SMITH; JOHN MCCRACKEN, APPELLEES ADMINISTRATIVE LAW JUDGE; AND WORKERS’ COMPENSATION BOARD

AND

2023-SC-0484-WC

HUNTER SMITH CROSS-APPELLANT

ON APPEAL FROM COURT OF APPEALS V. NO. 2023-CA-0604 WORKERS’ COMPENSATION NO. WC-21-95319

LABORATORY CORP OF AMERICA CROSS-APPELLEE

JOHN MCCRACKEN, APPELLEES ADMINISTRATIVE LAW JUDGE AND WORKERS’ COMPENSATION BOARD

OPINION OF THE COURT BY JUSTICE NICKELL

AFFIRMING Laboratory Corp of America (“Labcorp”) has appealed from the decision of

the Court of Appeals which affirmed a decision of the Workers’ Compensation

Board (“Board”) affirming an Administrative Law Judge’s (“ALJ”) Opinion and

Order awarding Hunter Smith permanent partial disability (“PPD”) benefits for

a work-related back injury with psychological overlay. Labcorp asserts the

Court of Appeals and the Board erred by affirming the ALJ’s adjudication of

Smith’s psychological injury which it contends was improperly based on a

conditional impairment rating. Smith has cross-appealed, alleging the ALJ

improperly adjudicated the permanent impairment rating relative to his back

injury. Following a careful review, we affirm.

FACTS AND PROCEDURAL HISTORY

Smith was employed by Labcorp as a phlebotomist. The events

precipitating this workers’ compensation claim occurred on January 27, 2021,

when a shelving unit fell onto Smith’s head, knocking him to the ground. He

sustained acute injuries to his lower back which required surgical intervention.

On April 4, 2021, Dr. Gregory Lanford performed a Left L4-5 hemilaminectomy,

medial facetectomy, diskectomy, and foraminotomy. The surgery was not

successful at alleviating Smith’s symptoms, with Dr. Lanford noting during

follow-up visits that Smith had burning pains in his legs exacerbated by

standing and walking, mechanical back pain, urinary urgency, urinary leakage,

back stiffness, and inability to sleep. Dr. Lanford ultimately assessed a 24%

permanent impairment rating relative to the back injury, apportioning 5% to

pre-existing injuries and 19% to the work-related injury. He recommended 2 Smith not engage in prolonged standing or walking, refrain from repetitive

climbing of stairs, and never work from ladders, scaffolds, or unprotected

heights. Dr. Lanford indicated Smith would need to sit and rest periodically for

relief of his pain.

Dr. Jules Barefoot examined Smith on November 10, 2021. At that time,

Smith had complaints of lower back pain radiating to his thigh, numbness in

his leg, and burning pain in his calf, all worsened with walking. Dr. Barefoot

also noted urinary urgency and dribbling and difficulty sleeping due to back

and leg pain. Smith freely admitted to experiencing prior back issues but Dr.

Barefoot indicated no surgery or restrictions had been recommended prior to

the work injury. Although some of Smith’s prior medical records noted active

back pain, others did not, including a physical therapy report issued two days

prior to the work injury. Dr. Barefoot’s recommended restrictions mirrored

those given by Dr. Lanford. Additionally, utilizing the ROM 1 method Dr.

Barefoot agreed with Dr. Lanford that Smith’s permanent impairment rating

was 24%, with 19% attributable to the work injury and 5% to pre-existing

active impairment.

Dr. Michael Best performed a medical examination and records review on

behalf of Labcorp. Dr. Best disagreed with the other physicians, noting Smith

was uncooperative, confrontational, and displayed significant magnification of

his symptoms. Dr. Best opined all of Smith’s back issues were pre-existing

1 Range-of-motion.

3 before the workplace incident, relying on information contained in the physical

therapy note issued two days prior to the shelf collapse. He further believed

Dr. Barefoot had ignored the appropriate method of assessing an impairment,

instead finding Smith has a Lumbar DRE 2 Category III 10% impairment, all of

which he attributed to a pre-existing active condition.

Dr. Barefoot subsequently reviewed Dr. Best’s report and opined Dr. Best

had misread Smith’s physical therapy note to say Smith had active back pain

two days before the workplace incident when, in fact, Smith had reported no

pain or tenderness and exhibited normal movements. Dr. Barefoot stood firm

in his previous impairment assessment and was unswayed by Dr. Best’s

opinions. Dr. Barefoot noted his belief the ROM method was indicated as the

appropriate assessment tool, but did not challenge Dr. Best’s use of the DRE

method as medically inappropriate or improper.

Dr. Robert Sivley evaluated Smith’s psychological complaints and issued

a report on January 5, 2022. Prior to the work injury, Smith had participated

in one or two counseling sessions during his mid-20’s for relationship issues,

but otherwise had no psychiatric history. Following a battery of psychological

tests, Dr. Sivley diagnosed Smith with adjustment disorder with mixed anxiety

and depressed mood, moderate to severe. Although Dr. Sivley diagnosed a

Class II impairment range, he refrained from providing a percentage of

impairment because he was unsure if Smith had attained maximum medical

2 Diagnosis-related estimate.

4 improvement (“MMI”) as he had not received any treatment for his mental

health issues. Several weeks later, Dr. Sivley provided an addendum to his

report assessing a 20% impairment rating for Smith’s psychological condition

upon concluding Smith had reached MMI as he was unable to obtain payment

from Labcorp for mental health treatment.

Dr. Amy Trivette performed a medical evaluation of Smith on behalf of

Labcorp on June 6, 2022. Because she is not a psychologist and cannot

administer psychological tests, Dr. Trivette engaged Dr. Martine Turns to

conduct the examination and testing. In reviewing the results, Dr. Trivette

concluded Smith was genuine in some responses but in others showed a

degree of symptom exaggeration and over-reporting of symptoms which were

not fully accounted for by his medical records. She believed the

inconsistencies made reliance on Smith’s accounts of his condition suspect.

Dr. Trivette found Smith did not demonstrate significant psychiatric

impairment resulting from the work injury nor did he suffer a mental disorder

which would prevent performance of his work duties. Thus, upon concluding

Smith did not have a psychological impairment relative to his work injury, Dr.

Trivette assessed him a 0% impairment rating.

After considering all of the evidence, the ALJ issued an opinion, award,

and order on July 15, 2022. The ALJ determined Smith had carried his

burden of establishing a compensable work-related injury. The ALJ awarded

Smith medical expenses and permanent partial disability benefits. For the

back injury, the ALJ rejected Dr. Best’s determination that all of Smith’s

5 symptoms resulted from a pre-existing condition, but nevertheless accepted his

10% impairment assessment as the most appropriate. Agreeing with a portion

of Dr. Barefoot’s assessment, the ALJ determined 5% of Smith’s impairment

was attributable to a pre-existing active condition, thus leaving a 5%

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Laboratory Corp. of America v. Hunter Smith, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laboratory-corp-of-america-v-hunter-smith-ky-2024.